Assess whether the exam response should concede a finding (0551e8)

SITUATION After a DOJ or CFPB monitor request for pricing files, HMDA LAR validity and quality edits is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a DOJ or CFPB monitor request for pricing files for fair-lending officer. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision the exam response should turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the exam response should. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the exam response should for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.

COMMAND RETURNS - Bottom-line Fair Lending option on the exam response should, then the evidence in HMDA LAR validity and quality edits, then the action for fair-lending officer - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in a manufactured-housing lender with dealer-originated files